Planning matters

Historic England (HE) recently published a consultation draft on preparing statements of heritage significance, setting out how the requirements of the National Planning Policy Framework (NPPF) can be met on that front.[1] While Historic England has previously produced a wide variety of guidance documents aimed at helping owners, occupiers and developers understand the significance of heritage assets, this consultation draft helpfully brings together both NPPF policy and HE guidance.
The NPPF defines heritage significance as being ‘the value of a heritage asset to this and future generations because of its heritage interest’, which may be archaeological, architectural, artistic or historic. The HE consultation draft guidance adopts these terms, helpfully aligning with the NPPF terminology in lieu of ‘evidential, historical, aesthetic and communal’ values formerly referred to in HE’s Conservation Principles, Policies and Guidance (April 2008, currently under review).
The draft guidance emphasises the importance of understanding heritage significance as a process separate from preparing the scheme proposals or designing out harm to significance. While this sequence is important, it also recognises that as designs develop and investigation works are carried out, an asset’s significance may be better revealed or understanding of it may change. Understanding significance is not a linear process, but it should form an important baseline.
For Southbank Centre, a statement of significance and diagrams illustrating areas of importance formed key parts of the accessible conservation plan for the site.
Proportionality in assessments is highlighted in the draft guidance: it notes the NPPF recognises that information on heritage assets should be proportionate to their importance and no more than is sufficient to understand the potential impact. The draft guidance helpfully explains that streamlined assessments are appropriate for straightforward cases, minimal impacts or changes to areas of the building of secondary or tertiary date and significance. Depending on the complexity of the asset and the proposals, a statement of significance and impact can form part of a covering letter or Design and Access Statement, or can comprise a detailed, stand-alone assessment.
The draft guidance also touches on the methodology used to assess significance: it identifies that while sensitivity matrices and scoring systems can be useful quantitative tools, ultimately “significance and impact are matters of qualitative and expert judgment”. Any quantitative methods should be used in conjunction with a narrative argument identifying what contributes to significance, why it matters and how the proposal would affect the asset’s significance.
Our statement of significance on West Horsley Place - a Grade I listed Tudor mansion - utilised both quantitative and qualitative methods of assessing the significance of the wider site.
As practitioners, we agree with paragraph 6 of the draft guidance, which highlights that it is crucial for significance to be identified up front to save abortive work and cost. However, it is difficult to define a proportionate scope of assessment without having an initial scheme in which to respond. The process needs to be iterative and may require a staged approach to understanding significance, with more detailed assessment of significance carried out on areas where alterations are proposed.
We note in paragraph 10 of the draft guidance that applicants are encouraged to agree the precise extent and nature of an assessment of significance with the local planning authority. While this is laudable best-practice, it is often unrealistic given the time constraints upon local planning authority conservation officers and difficulties getting in touch with them as a result. In addition, costs and time delays associated with pre-application consultation may mean that in practice, agreeing the scope of the assessment of significance with the conservation officer in advance may not always be practicable.
When Historic England (as English Heritage) published Conservation Principles in 2008, this was a milestone in a qualitative approach to heritage significance. It encourages the practitioner to consider why an asset is important and this thinking has been incorporated into the NPPF. However, the question of how to assess the scale of that significance (how important is the asset) has not been addressed in policy or guidance even though it is an essential consideration in the balancing process that is the planning system. This new guidance stresses the need to identify the level of significance but leaves such evaluation to expert judgement. Given the difficulty in codifying such a process for the whole range of asset types this may be the most sane approach to take.
[1] Historic England: Guidance open for consultation

A culmination of an intensive and exciting period of work for Lichfields proved fruitful at Westminster City Council’s Planning (Major Applications) Sub-Committee, when planning permission and listed building consent were granted for the ‘Inspiring People’ project at the National Portrait Gallery.
This £35.5m project, designed by Jamie Fobert Architects working alongside conservation architects Purcell, will transform the Grade I listed Gallery, making it more accessible and welcoming to the public as well as restoring historic features. At its core is a comprehensive redisplay and re-interpretation of the Gallery’s permanent Collection across 40 refurbished galleries, presenting a greater and more diverse selection of portraits; the return of the Gallery’s East Wing to public use as the new Weston Wing, including restoring the original gallery spaces and the creation of new retail and catering facilities; and a new Learning Centre for visitors of all ages with studios, breakout spaces and high quality practical facilities.
Externally a new public forecourt is to be created on the northern side of the building leading to a new fully-accessible entrance in the north façade which is more open and welcoming to all and will create a step-change in the quality of the townscape at the southern end of Charing Cross Road.
Image credit: Jamie Fobert Architects + Purcell
For a high-profile central London site, the application ran particularly smoothly with not a single objection to the project received. The success of the project, while down to the Gallery’s vision and clearly articulated need for the alterations to take place together with the sensitive and inspired response of the architects, also lay in the strong consultative approach the project team took to the planning and listed building consent application.
Our pre-application strategy involved working closely with Westminster City Council, neighbours, stakeholders and relevant consultees to ensure any concerns were taken on board and addressed in the design of the scheme. As part of the integrated design team, Lichfields led early engagement with Westminster City Council to establish a positive working relationship with the Council from the outset.
In co-ordination with the Gallery and wider design team, we also carried out pre-application public consultation and engaged with statutory consultees including Historic England, the Victorian Society and the 20th Century Society, as well as local consultees such as the Westminster Society and the Irving Society. A series of design workshops were held jointly with Historic England and Westminster City Council to develop the scheme to a design that was supported in principal by all parties prior to the submission of the applications.
We entered into a Planning Performance Agreement with the Council which covered the determination period. The committee date of 23rd April was agreed upon by all parties and a collaborative working relationship was established between the applicant team and the Council to ensure that the applications were submitted on time and any concerns and issues were dealt with speedily to enable the applications to be heard on the identified date.
We look forward to continuing to work closely with the Council over the coming months to discharge the planning conditions and sign the legal agreement.